You must disclose your significant financial interests (SFIs) and SFIs of your family when your funding proposal is submitted to the university or before you work on an award subject to additional FCOI compliance. (Looking for more information about FCOI and SSQ? Start here.)
You must update your disclosure annually and within 30 days of any newly acquired or discovered SFIs or changes in the reported SFIs on awarded grants (regardless of the type of award, including federal flow-through) and extensions (with or without funding).
Go to START myDisclosures to complete the Sponsor Specific Questionnaire (SSQ).
Examples of Significant Financial Interests Required to be Reported:
| Financial Interest | Examples | Thresholds for SFI |
| Remuneration, income, salary, and any payment for services | Consulting fees, honoraria, paid authorship. | $5,000 or more. |
| Public equity interest | Stock, stock option, or other ownership interest. | The present-day market value of $5,000 or more. |
| Private equity interest | Stock, stock option, or other ownership interest. | Any ownership interest regardless of percentage or the dollar value. |
| Intellectual property (IP) rights and interests | Patents not assigned to the University of Illinois; licenses from the University of Illinois to an external entity; copyrights; royalties that are not paid by the University of Illinois. | When profit or remuneration from IP interests meets or exceeds $5,000. |
| Fiduciary role | The executive role is a voting member of the board. | Report fiduciary relationships (even if unpaid) that may be reasonably related to your research or university responsibilities; or with an entity that does business with the university. |
| Sponsored or reimbursed travel | Travel paid by an external entity (including airfare, gas, car rental, hotel room meals, stipends, etc.). Travel must be reported from any entity unless the travel is reimbursed or sponsored by a federal, state, or local government agency, an institution of higher education as defined by 20 U.S.C. 1001(a); an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education. | $5,000 de minimis for reporting. |
| Foreign financial interests | Financial interests are received from a foreign institution of higher education or the government of another country (which includes local, provincial, or equivalent governments of another country). | $5,000 or more. |
Interests Exempt From This Reporting Requirement
EXEMPTIONS
You do not need to disclose:
- Salary, royalties, or other remunerations paid by the University of Illinois; including intellectual property rights assigned to the University of Illinois and agreements to share royalties related to such rights.
- Income from investment vehicles (mutual funds or retirement accounts that are not managed directly by the individual).
- Income from seminars, lectures, or teaching engagements sponsored by a US federal, state, or local government agency, a U.S. Institution of higher education as defined by 20 U.S.C. 1001(a); an academic teaching hospital, a medical center, or a research institute that is affiliated with a U.S. institution of higher education.
- Income from service on advisory committees or review panels for a US federal, state, or local government agency, a U.S. institution of higher education as defined by 20 U.S.C. 1001(a). (e.g., NIH review panel).
- Travel that is reimbursed or sponsored by a US federal, state, or local government agency, a U.S. institution of higher education as defined by 20 U.S.C. 1001(a); an academic teaching hospital, a medical center, or a research institute that is affiliated with a U.S. institution of higher education.
Managing COI in Human Subjects Research
To better align with federal regulations and University of Illinois System policies, all research team members for a human subject research project are required to provide a financial disclosure. The IRB/OPRS is required by regulation and System policy to ensure that no research team members have a financial conflict of interest with the research, and if a conflict exists, the conflict is appropriately managed. The Conflict of Interest Office works with OPRS to meet these requirements. Research team members should begin filing their disclosures immediately utilizing START myDisclosures.
After March 23, 2026, human subject research projects cannot be approved unless all research team members have no significant financial interests in the research being conducted, or the conflict has been managed in accordance with COI and IRB requirements. Please visit the OPRS website for more details.
For Model Language for Disclosing Financial Interests to Potential Research Participants, please visit https://go.illinois.edu/COIModelLanguage.
This template provides various examples to use on informed consent documentation when a conflict of interest management plan indicates the conflict will be disclosed to human subject research participants.